BFSG: Running Chatbots and Voicebots Accessibly
Since 28 June 2025, the German Accessibility Strengthening Act (BFSG) has been in force. It covers chatbots on the web and voicebots on the phone alike, but with different requirements. Companies that serve both channels from one platform gain a structural compliance advantage.
Does the BFSG apply to chatbots?
Yes, whenever the chatbot is part of a B2C service within scope, such as e-commerce, banking, passenger transport or telecommunications. The reference norm is EN 301 549 chapter 9, pointing to WCAG 2.1 conformance levels A and AA. In practice this means screen reader compatibility with JAWS, NVDA and Windows Narrator, full keyboard operability, sufficient colour contrast, scalability up to 200 percent zoom, a visible keyboard focus and semantic HTML with ARIA annotations.
Does the BFSG apply to voicebots and phonebots?
Yes, under the same conditions. On the phone, chapter 6 of EN 301 549 applies. The central requirement is DTMF as an equivalent input alternative to speech recognition, so people with speech impairments can operate the agent. Prompts must be repeatable, timeouts generous, pace appropriate. Visual references in audio prompts are out, as is voice biometrics without an alternative path. Handover to a Live Agent must remain accessible at all times.
Which obligation links chatbot and voicebot?
The multi-channel principle under § 12 BFSGV. Information must be available through more than one sensory channel. A voice-only bot without a textual counterpart excludes deaf and hard-of-hearing users. A chat-only bot without an audio alternative covers screen reader use, but leaves users without digital routine without channel choice. Companies that offer chat and phone from one source meet the multi-channel principle structurally, not just formally.
Is a FAQ bot enough for BFSG compliance?
Technically, a WCAG-compliant widget covers the chat requirements. Substantively, it does not. § 19 BFSGV demands functions that are understandable, operable and robust. A FAQ bot that responds to complex inquiries with “Sorry, I did not understand” is neither operable nor robust in the sense of the norm. AI Agents that resolve customer inquiries end-to-end meet the spirit of the law. A FAQ bot operates at the edge.
Which language level does the BFSG require?
For banking services, § 17 (2) BFSGV mandates a maximum language level of B2. Outside banking, the state of the art applies. For both channels this means short sentences, clear structure and no technical jargon. In the LoyJoy Platform, AI Agent output can be configured to remain consistently at the required level across chat and phone, without losing the brand voice.
What needs to be documented?
Providers need an accessibility statement on their website covering the requirements met, a feedback channel and the responsible market surveillance authority (Annex 3 BFSG). Compliance with EN 301 549 triggers the conformity presumption under § 4 BFSG. The norm serves as the pragmatic reference point for compliance documentation.
How LoyJoy supports customers in BFSG implementation
Chat and phone run on the same process logic of the LoyJoy Platform. One configured AI Agent serves both channels and structurally meets the multi-channel principle. A WCAG-compliant chat widget, DTMF fallback in the voicebot, defined Live Agent handover, controllable language level and end-to-end documentation all emerge from one configuration. Instead of running two compliance projects in parallel, customers address both BFSG requirements in one setup. Made in Germany, hosted in the EU and designed for GDPR, DORA, BFSG and the EU AI Act. Less effort, less risk, less friction in regulated industries such as banking, insurance, energy and telecommunications.
The BFSG accessibility statement for the LoyJoy Platform is available in the LoyJoy Trust Center.